1.
WHICH OF THE FOLLOWING IS A HIGH RISK ACTIVITY?
Correct Answer
A. MONEY TRANSFERS TO UNKNOWN THIRD PARTIES
Explanation
Money transfers to unknown third parties are considered a high-risk activity because there is a higher likelihood of fraudulent or illegal transactions taking place. Transferring money to unknown individuals or organizations increases the chances of money laundering, terrorist financing, or other illegal activities. It is important to exercise caution and due diligence when engaging in such transactions to mitigate the risks involved.
2.
WHICH OF THE FOLLOWING TERMS IS USED TO DESCRIBE THE PROCESS OF SENDING MONEY THROUGH MULTIPLE FINANCIAL INSTITUTIONS TO MAKE IT DIFFICULT TO TRACK?
Correct Answer
D. LAYERING
Explanation
Layering is the correct answer because it refers to the process of sending money through multiple financial institutions in order to make it difficult to track. This involves moving funds through various transactions and accounts, often in different countries, to create a complex and convoluted trail that makes it challenging for authorities to trace the origin and destination of the funds. This technique is commonly used in money laundering schemes to obscure the illicit source of funds and make it harder for law enforcement agencies to detect and investigate financial crimes.
3.
IN THE U.S., BANKS MUST REPORT DEPOSITS OF $10000.00 OR MORE. WHAT IS THE TERM FOR BREAKING UP LARGE SUMS OF MONEY INTO SMALLER AMOUNTS FOR DEPOSIT?
Correct Answer
D. SMURFING
Explanation
Smurfing is the term used to describe the act of breaking up large sums of money into smaller amounts for deposit. This is done to avoid triggering the reporting requirement for deposits of $10,000 or more in the U.S. Smurfing involves multiple individuals, known as smurfs, making smaller deposits individually to avoid suspicion and detection by authorities. By breaking up the large sum into smaller amounts, the individuals involved aim to fly under the radar and avoid scrutiny from banks and law enforcement agencies.
4.
THE PERSONAL RAMIFICATIONS OF AML NON-COMPLIANCE INCLUDE:
Correct Answer(s)
A. FORFEITURE OF PROPERTY
D. SUBSTANTIAL LEGAL FEES
E. FINES UP TO $500,000 OR DOUBLE THE AMOUNT INVOLVED IN THE TRANSACTION, WHICHEVER IS GREATER
F. TERMINATION OF EMPLOYMENT
G. PRISON TERMS UP TO 20 YEARS
Explanation
The personal ramifications of AML non-compliance include forfeiture of property, substantial legal fees, fines up to $500,000 or double the amount involved in the transaction (whichever is greater), termination of employment, and prison terms up to 20 years.
5.
MONEY LAUNDERING IS THE PROCESS BY WHICH THE PROCEEDS OF CRIMINAL ACTIVITY ARE INTRODUCED INTO LEGITIMATE MAINSTREAM OF FINANCIAL COMMERCE.
Correct Answer
A. True
Explanation
Money laundering is the process of making illegally obtained money appear legal by passing it through a complex sequence of banking transfers or commercial transactions. This allows the funds to be integrated into the legitimate financial system without raising suspicion. Therefore, the statement that money laundering is the process by which the proceeds of criminal activity are introduced into the legitimate mainstream of financial commerce is true.
6.
IF A REGULAR CUSTOMER CONDUCTS A CASH TRANSACTION INVOLVING MORE THAN $10,000, WE ARE NOT REQUIRED TO FILE A CTR.
Correct Answer
B. False
Explanation
If a regular customer conducts a cash transaction involving more than $10,000, we are required to file a CTR. This is because the Bank Secrecy Act (BSA) requires financial institutions to report any cash transactions exceeding $10,000 in order to prevent money laundering and other illegal activities. Filing a Currency Transaction Report (CTR) helps the authorities track and monitor large cash transactions and ensures compliance with anti-money laundering regulations. Therefore, the statement that we are not required to file a CTR for such transactions is false.
7.
THE BANK SECRECY ACT REQUIRES FINANCIAL INSTITUTIONS TO
Correct Answer(s)
A. REPORT SUSPICIOUS ACTIVITIES
C. FILE CURRENCY TRANSACTION REPORTS WITH THE IRS
Explanation
The Bank Secrecy Act requires financial institutions to report suspicious activities and file currency transaction reports with the IRS. This is to ensure that any potential illegal or suspicious financial activities are identified and reported to the appropriate authorities. By reporting suspicious activities and filing currency transaction reports, financial institutions can help prevent money laundering, terrorist financing, and other criminal activities.
8.
A CUSTOMER BRINGS IN $12,000 IN CURRENCY AT ONE TIME AND REQUESTS THREE SEPERATE CASHIERS CHECKS OF $4,000 EACH. A CTR IS NOT REQUIRED.
Correct Answer
B. False
Explanation
False. According to the Bank Secrecy Act, any transaction involving more than $10,000 in currency must be reported on a Currency Transaction Report (CTR). In this case, the customer is bringing in $12,000 in currency, which exceeds the reporting threshold, so a CTR would be required.
9.
LAUNDERERS MIGHT ATTEMPT A SERIES OF SMALL CURRENCY TRANSACTIONS OVER TIME BECAUSE
Correct Answer
A. A PROVISION OF THE BANK SECRECY ACT REQUIRES THE FILING OF A CTR FOR TRANSACTIONS EXCEEDING $10,000
Explanation
Launderers might attempt a series of small currency transactions over time because a provision of the Bank Secrecy Act requires the filing of a Currency Transaction Report (CTR) for transactions exceeding $10,000. This means that if a single transaction exceeds $10,000, it will be reported to the authorities, raising suspicion and potentially attracting unwanted attention. By conducting multiple smaller transactions, launderers can avoid triggering the reporting threshold and attempt to conceal their illicit activities.
10.
A CUSTOMER BUYS CASHIERS CHECKS FOR $5,999 CASH ON MONDAY, $9,000 CASH ON WEDNESDAY, $9,500 CASH ON THURSDAY, AND $8,000 CASH ON FRIDAY. THIS DESERVES MORE INVESTIGATION AS A POTENTIAL CASE OF STRUCTURING.
Correct Answer
A. True
Explanation
The given answer is true because the customer is making multiple cash purchases of cashier's checks in amounts just below the $10,000 threshold that triggers reporting requirements under the Bank Secrecy Act. This behavior is known as structuring, which involves intentionally breaking up large cash transactions into smaller ones to avoid detection and reporting by financial institutions. Structuring is illegal and is often associated with money laundering or other illicit activities. Therefore, the customer's actions deserve further investigation to determine if they are engaged in suspicious or illegal activities.
11.
A CUSTOMER COMES IN FOUR DAYS IN A ROW, EACH TIME REQUESTING A WIRE TRANSFER OF $2,900. YOU DO NOT NEED TO REPORT THIS AS A SUSPICIOUS ACTIVITY.
Correct Answer
B. False
Explanation
This statement is false because a customer coming in four days in a row and requesting wire transfers of the same amount each time could be considered suspicious activity. This pattern may indicate potential money laundering or fraudulent activity, and it should be reported to the appropriate authorities for further investigation.
12.
WHICH OF THE FOLLOWING ARE EXAMPLES OF WILLFUL BLINDNESS?
Correct Answer
E. ALL OF THE CHOICES APPLY
Explanation
All of the choices provided in the question are examples of willful blindness. Willful blindness refers to the act of intentionally ignoring or avoiding knowledge or information that could indicate illegal or unethical behavior. Allowing a customer to purchase money orders under different names, selling multiple money orders without recording the customer's ID, completing a transaction for a smaller amount after a customer refuses to produce ID for a larger transaction, and cashing a check for someone who is not the payee all demonstrate a deliberate disregard for potential suspicious activity and are therefore examples of willful blindness.
13.
FOR THE MONEY LAUNDERING PROCESS TO BE A SUCESS, TRANSACTIONS SUCH AS CURRENCY EXCHANGE, WIRE TRANSFERS, AND MONEY ORDERS NEED TO COMPLETED WITHOUT ANY PAPER TRAIL.
Correct Answer
B. False
Explanation
The statement suggests that for money laundering to be successful, transactions such as currency exchange, wire transfers, and money orders need to be completed without any paper trail. However, this is incorrect. In reality, money laundering involves disguising the origins of illegally obtained money by making it appear legitimate. This often involves creating a complex web of transactions and paper trails to obscure the source of the funds. Therefore, the statement is false.
14.
WHICH OF THESE ACTIVITIES MIGHT REQUIRE A SUSPICIOUS ACTIVITY REPORT?
Correct Answer
E. ALL OF THESE ACTIVITIES
Explanation
All of these activities might require a suspicious activity report because they all involve behaviors that are indicative of potential illegal or illicit activities. Canceling a transaction and requesting a second transaction for a lower amount to avoid providing identification raises suspicions of money laundering or fraud. Requesting an unusually high dollar transaction without a clear reason or source of funds suggests possible illicit financial activity. A nervous customer asking unusual questions about record-keeping may be attempting to gather information for fraudulent purposes. Finally, attempting to bribe a teller is a clear violation of ethical and legal standards and should be reported.